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who wish to pursue a career driving as long as they meet the revised diabetes standard and/or physician guidelines.

Comments on Rulemaking and Analyses and Notices

In addition to the thirteen areas identified above for comment, FMCSA also noted that it seeks comments on two additional issues to help guide its analysis for potential proposed rulemaking:

  • (1)

    The costs and benefits of potentially effective and reasonably feasible alternatives to the current regulations, including improving the current regulation and reasonably viable non-regulatory actions; and

  • (2)

    Any preliminary impact assessments of these regulatory and non-regulatory alternatives on the health of CMV drivers with ITDM.

The Association stresses that changing the current process from an exemption program to a regulatory scheme that allows for individual assessment and certification of medically qualified individuals with diabetes will have a significant positive impact on the lives of individuals with diabetes, their families, employers, and the economy by adding to the pool of safe, productive, experienced drivers. Throughout these comments, the Association has noted the potential benefits of such as system from both a medical and a practical perspective, as well as the provisions of the current system that should and should not be retained in a new regulatory scheme. A far inferior alternative would be to maintain the current exemption program but with the changes proposed in this comment and with sufficient staffing at FMCSA to meet the program’s own requirements for application processing. Further, the Association reiterates what we stated above in response question 2: there is nothing about commercial driving that makes it a dangerous or inadvisable occupation for someone with insulin-treated diabetes as long as the individual is able to maintain his or her blood glucose within a safe range while driving.

The American Diabetes Association appreciates the opportunity to comment on proposed changes to the system for individual assessment of potential commercial drivers with insulin-treated diabetes and would be happy to provide any additional information or assistance as reexamination of the current process continues.

Contact information:

Shereen Arent (703) 299-5519 sarent@diabetes.org


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